WholeLife Privacy Policy

Introduction

WholeLife Pharmacy Pty Ltd are committed to maintaining your privacy in accordance with the Australian Privacy Principles (APPs) and the Privacy Act 1988 (Cth).

This Privacy Policy sets out how WholeLife Pharmacy Pty Ltd manages the personal information that we collect, access, store and use in the course of operating our business.

If you provide us with personal information about someone else you must have their consent or otherwise be lawfully permitted to disclose that information to us.

Part 1 – Suppliers, customers, loyalty program members and others

Part 1 of this Privacy Policy describes how we handle personal information from people that are not Patients (as defined in Part 2). This includes:

actual and prospective suppliers of goods and services to WholeLife Pharmacy Pty Ltd;
customers of WholeLife Pharmacy Pty Ltd (such as pharmacies, people who enquire or make purchases via our website (wholelife.com.au) and users of our apps;
members of loyalty programs for our community pharmacy brands (e.g. Wholelife Vibe); and
job applicants.

In Part 1, ‘you’ refers to these people and, where relevant, the staff members of actual and prospective suppliers and customers.

What types of personal information do we collect about you?

The kinds of personal information we collect about you will depend on the circumstances and purposes of collection, but will typically include:

your name, contact information, date of birth;
financial information (including credit card details or bank account numbers);
where relevant, information about your employer or an organisation you represent and/or your professional details (e.g. AHPRA number);
information about the business or activities of you or your employer or an organisation you represent;
for actual or prospective suppliers, the products and services you may or do provide WholeLife Pharmacy Pty Ltd;
for actual or prospective customers, the products and services you may or do obtain from WholeLife Pharmacy Pty Ltd and transactional information about your use of our products and services;
for Loyalty Program members, your preferred community pharmacy participating in the Loyalty Program, transactional information about the products and services that you may or do obtain via community pharmacies participating in the Loyalty Program (if you swipe your Loyalty Program card or otherwise provide your Loyalty Program details);
for WholeLife Pharmacy Pty Ltd Apps, location data passed on from third party services or GPS-enabled devices you have set up and other information obtained from the networks and devices that you use to access the Sigma App;
your opinion/preferences about specific products and services;
to the extent required or permitted by law, a government related identifier (e.g. Medicare number).

In some cases the information we collect will be sensitive information, such as your membership of a professional or trade association. For Loyalty Program members, some of the information we collect may be health information (e.g. information about the products and services you have obtained via a community pharmacy in the Loyalty Program).

The lists above are not exhaustive. We may sometimes need to collect additional information.

How and when do we collect personal information?

We may collect your information in a number of ways, including:

directly from you or those authorised to provide information on your behalf (such as where you provide information to us when you complete an application form or agreement for one of our services, contact us with a query or request, fill in a survey, or enter a competition, and including by monitoring and recording your interactions with us, such as via email and telephone); from third parties such as our related entities, business or commercial partners,
via use of video and audio surveillance devices at our premises;
from publicly available sources of information;
automatically through WholeLife Pharmacy Pty Ltd Apps you have downloaded;
when you scan your Loyalty Program card or provide your Loyalty Program number at a participating community pharmacy or on our website; or
from our records of how you use the products or services provided by us including in respect of any website controlled by us.

We will only collect your sensitive information if you have consented to the collection and the information is reasonably necessary for, or directly related to, one of our functions or activities or we are otherwise legally permitted to collect the information.

Where we have collected your personal information on behalf of a third party, the collection and use of that information may be governed by their privacy policy. We may combine information we collect about you from multiple sources.

When we obtain personal and other information from third parties whom we are referred to by you we will assume and you will ensure that you have made that third party aware of the referral of the persons and purposes involved in the collection, use and disclosure of the relevant personal or other information.

We will assume you consent to the management of your personal information in the manner specified in this Privacy Policy (which may change from time to time) until you tell us otherwise by contacting the Privacy Officer.

Why do we collect, hold, use and disclose your personal information?

We collect, hold, use and disclose your personal information for our functions and activities which include, amongst other things:

providing, offering or communicating with you about products and services (including products and services offered by third parties, such as community pharmacies participating in our Loyalty Programs);
allowing Loyalty Program members to accrue and redeem loyalty points and receive special offers;
inviting you to enter competitions or complete surveys and conducting product and market research;
to enable third parties to communicate with you about products and services they provide;
being aware of any special product and service requirements you may have;
to fulfil administrative functions associated with our business, such as order processing, billing, debt recovery, entering into contracts, managing relationships, planning, managing and monitoring our activities, products and services, training staff, contractors and other workers, risk management and management of legal liabilities and claims, obtaining advice from consultants and other professional advisers;
providing you with information about charities or charitable initiatives that we support;
to comply with any legal or regulatory obligations imposed on us;
addressing any questions, feedback or complaints you may have;
developing, improving and marketing our products and services; and
any purposes for which it was requested and any secondary purposes to which you have consented or for which we are lawfully allowed to use your information.

We may also use and disclose your personal information, including information about Loyalty Program members, for the purpose of direct marketing, targeted advertising and special promotions, or to facilitate third parties (such as community pharmacies participating in our Loyalty Programs) direct marketing to you.

We will only use your sensitive information (such as health information that may be captured via the Loyalty Program) for these purposes with your consent. You may opt out of our direct marketing to you. Our direct marketing materials will tell you how to do this.

Personal information we collect from you may be disclosed for the above purposes or as otherwise lawfully permitted, including to:

any entity to which we are required or authorised by or under law to disclose such information (for instance, Federal or State law enforcement agencies and investigative
agencies, courts, various other Federal or State government bodies);
contractors and service providers we engage in order to provide our products and services and/or conduct the functions described above (for example IT consultants and mailing
houses);
our professional advisers and consultants;
our business associates;
third parties in a de-identified format for research purposes (including the development of third party products and services); or
others that you have been informed of at the time any personal information is collected from you or to which you have consented (express or implied).

Your consent to us disclosing your personal information to a third party may be implied from your use of the third party’s products or services which involve obtaining or accessing personal information from us or organisations like us or you enabling a third party to access your information held by us.

Where we disclose your information, we will (if possible) take such steps that are reasonable in the circumstances to de-identify the information.

Part 2 – Patients

Part 2 applies to people (other than Loyalty Program members) that we collect health information about, who are primarily patients of the pharmacies, nursing homes, and other health professionals and carers, that use certain products and services we provide (Patients).

In Part 2, ‘you’ refers to Patients. Loyalty Program members should refer to Part 1 of this Privacy Policy.

What types of personal information do we collect about you?

The types of information we collect will depend on which of our products and services you or your health professionals and/or carers use in relation to your care, and how those products and services are used. The types of information we typically collect includes:

your name, contact information, date of birth;
where legally permitted, a government related identifier (e.g. your Medicare or Department of Veteran Affairs number);
your photograph, where this is required to identify you (e.g. on your dose administration aid);
details of your health and care service providers and others involved in your care (e.g. next of kin/medical power of attorney/informal carers);
your medical history and medical conditions;
your pharmaceutical prescriptions;
details of your interactions and transactions with us or your health professionals and/or carers that use our products and services in relation to your care, such as medication and/or care you have received, requested or have been recommended and other clinical notes recorded in our software or provided to us by your health professionals and/or carers if you use our appointment booking portal, whether you attended your appointment;
your opinions on the services provided by your health and care service The information we collect about Patients is sensitive information and will be handled as such.

How and when do we collect your personal information?

We generally collect personal information (including health information) if you or your community pharmacy, nursing home, home care provider, and/or other health professionals and carers, use certain products and services we provide in relation to your care, such as:

dose administration aid packing services;
medication management, prescribing, dispensing and packing software (e.g. Healthstream, Quantum);
home care assistance services (e.g. automated medication follow-up reminders);
our appointment booking portal (e.g. for influenza vaccinations).

Where reasonable and practicable, we collect this information from you, such as by asking you to fill in a form or complete a survey.

However, in many circumstances, it will be unreasonable or impractical to obtain the information from you (e.g. you may not have the information, information from another source would contain fewer errors or be more complete, it would be unduly time consuming). In these cases, we will collect the health information from another source, such as:

your current or former health professional(s) or carer(s), including via their use of our software or website;
a third party who provides or provided goods or services to your current or former health professional(s) or carer(s) (e.g. a third party software provider previously used by your health professional who holds your historical medical records);
your next of kin or other informal carer.

We may combine the information collected from different sources to create a single record about you.

We may also collect personal information (including health information) from you or your community pharmacy, nursing home, home care provider, and/or other health professionals and carers, if you or your healthcare provider/professional provide us with information for pharmacovigilance purposes.

Why do we collect, hold, use and disclose your personal information?

We collect, hold use and disclose your personal information for purposes related to health and care services you receive, including:

to provide your health professionals and carers with products and services that they use to care for you and manage your care, such as packing your dose administration aids for dispensing by your pharmacist;
to share information we hold about you with your health professionals and other carers (including allowing them to access that information via third party software);
to allow you and others nominated by you or your carers (such as your next of kin) to keep track of the care you receive;
to develop and improve the products and services that we and our business partners provide;
to fulfil administrative functions associated with our business, such as order processing, billing, debt recovery, entering into contracts, managing relationships, planning, managing and monitoring our activities, products and services, training staff, contractors and other workers, risk management and management of legal liabilities and claims, obtaining advice from consultants and other professional advisers;
to investigate and report on any complaints, including product complaints for pharmacovigilance or other purposes;
to engage with regulators where required;
any other purposes we disclose to you at the time of collection, to which you otherwise consent, which is directly related to the purposes of collection or which is otherwise lawfully permitted.

For these purposes, your personal information may be disclosed to your health professionals and carers, others involved in your care as nominated by you or your health professionals or carers (such as your next of kin), third parties who provide related products and services to you or your health professionals and care service providers (such as third party software providers). This list is not is not exhaustive. We may also disclose your information to:

any entity to which we are required or authorised by or under law to disclose such information (for instance, Federal or State law enforcement agencies and investigative
agencies, courts, various other Federal or State government bodies);
contractors and service providers we engage in order to provide our products and services and/or conduct the administrative functions described above (for example IT consultants and mailing houses);
our professional advisers and consultants;
our business associates;
others that you have been informed of at the time any personal information is collected from you or to which you have consented (express or implied).

Part 3 – Information regarding vaccination status

Part 3 applies to WholeLife Pharmacy Pty Ltd and prospective employees for the purposes of the collection of COVID-19 and Influenza vaccination information.

Government Agency – means an ‘agency’ as defined in the Privacy Act and includes bodies which fall within comparative definitions in other Privacy Laws, as well as State and Territory governments, their agencies and law enforcement bodies.

Medical Exemption Information means information or opinion from a medical practitioner advising that, in their view, there are contraindications for the person in respect of currently available COVID-19 vaccinations, as defined by the ATAGI (Clinical Guidance on use of COVID-19 vaccination in Australia in 2021 (V7.4).

Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Personal information includes Sensitive Information.

Privacy Law means the Privacy Act 1988 (Cth) (Privacy Act), counterpart legislation operating in your State or Territory, and various State and Territory legislation related to health records, as applicable.

Sensitive Information is information or an opinion about certain matters involving an individual, which relevantly includes health information about an individual. Test Status Information means information regarding the time, date, location of the test, the type of test, the organisation or agency that administered it (for instance, the pathology provider, or public hospital) and the results of that test.

Vaccination Status Information means information regarding the date and type of COVID-19 vaccine that was received and the name of the health provider that administered it.

WholeLife Pharmacy Pty Ltd may collect and hold Personal Information, including Sensitive information, from individuals as part of the operation of its Workplace COVID-19 Vaccination Policy, or where Government authorities or facility owners impose vaccination requirements for employees to be able to access these facilities. information may include Vaccination Status Information, Test Status Information, and Medical Exemption Information, where this information is reasonably necessary for WholeLife’s management to support its operational requirements and/or where required or authorised by law.

Information will be collected for the primary purpose of preventing or managing the risk of COVID- 19 in WholeLife’s workplaces, and meeting customer vaccination requirements. Information may be collected for the secondary purpose of preparing for any necessary disclosures to a Government Agency or other body to respond to COVID 19, where required.

Sensitive Information will be sought by consent and used and disclosed in line with the primary purpose it was collected and may be used and disclosed for appropriate secondary purposes, unless an exception or exemption applies.

WholeLife will take steps that are reasonable in the circumstances to protect Personal Information which is collected via the operation of this Policy from misuse, interference and loss and from unauthorised access, modification or disclosure.

Part 4 – General provisions

Part 4 applies to all individuals that we collect personal information about, including Patients.

In Part 4, ‘you’ means any person we collect information about.

Interacting with WholeLife Website

You may visit the WholeLife Website without identifying yourself. If you identify yourself (e.g. by providing your contact details in an enquiry), we will handle that information in accordance with this Privacy Policy.

The WholeLife Website may contain link to third party sites. We are not responsible for the content or privacy practices of the third parties who operate those websites.

The WholeLife Website use “cookies”. A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we and/or our contractors use may identify individual users. Through cookies, we and/or our contractors may also collect information such as the software used, location data (unless disabled by the user), the date and time of your visit, your IP address, information you download and pages you have accessed on WholeLife Website and third party websites, browser types and type of device you use.

Cookies can either be “persistent” or “session” based. Persistent cookies are stored on your computer, contain an expiration date, and are mainly for the user’s convenience. Session cookies are short-lived and are held on your browser’s memory only for the duration of your session, they are used only during a browsing session, and expire when you quit your browser. We and/or our contractors may use both session and persistent cookies. This information may be used to personalise your current visit to our and our contractors’ websites. Upon closing your browser, the session cookie is destroyed.

Most internet browsers can be set to accept or reject cookies. If you do not want to accept cookies, you can adjust your Internet browser to reject cookies or to notify you when they are being used. However, rejecting cookies may limit the functionality of our website.

Protecting your information

We may store your information electronically or in hard copies. WholeLife will take reasonable steps to protect the personal information it holds from misuse, interference and loss and from unauthorised access, modification or disclosure.

WholeLife will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed and we are not legally required to retain it. Some personal information, such as Patient health records, must be retained.

Remaining anonymous

Where lawful and practicable, we will give individuals the option of remaining anonymous or using a pseudonym when dealing with us.

Generally, however, we will not be able to carry out our functions or activities described in this Privacy Policy if you choose to remain anonymous. If we do not collect personal information about you, we may not be able to provide you, or your health or care service providers, with products or services.

Quality, access and correction of our personal information

We will take such steps as are reasonable in the circumstance to ensure that the personal information that we collect or disclose is accurate, up-to-date and complete (in the case of disclosure, having regard to the purpose of the disclosure).

You have the right to request access to the personal information that we and/or our contractors hold about you and/or to request a correction of that information. Under some circumstances permitted by law, we may decline your request. Also, we may not be able to require our contractors to provide access to you or correct your information. All requests should be made to our Privacy Officer (preferably in writing) using the contact details below.

We may ask you to put your request in writing and pay a reasonable fee levied by us for this.

Transfer of your personal information overseas

Generally, we will not disclose your personal information to overseas recipients, but we may do so in some circumstances including for the purposes permitted in this policy or expressly agreed to by you. We will only do so to the extent it is lawful including where:

we have taken such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the APPs;
we reasonably believe that the recipient of the information is subject to a law or binding scheme which effectively protects information in a manner that is substantially similar to the APPs; or
you have consented to the transfer or the disclosure is allowed or required by law.

Complaints

You can contact our Privacy Officer using the details below to make a complaint about privacy or if you have any questions or concerns about our management or handling of your personal information or this Privacy Policy.

To enable us to understand and act upon your complaint, we recommend that complaints be made in writing and specify the personal information and the contact or process within WholeLife that are the subject of the complaint.

We will acknowledge receipt of your complaint within 5 business days of receipt and provide you with contact details of the person dealing with the complaint, where this is not the Privacy Officer. We endeavour to respond fully to complaints within 15 business days. If this is not possible, for example because a more detailed investigation or consideration is required due to the nature or complexity of the complaint, we will let you know and advise you when we expect to be able to respond.

If you are not satisfied with our response to your complaint, we will, in good faith, attempt to reach an agreement with you regarding an alternative process and time frame for dealing with the complaint. You may also refer your complaint to the Office of the Australian Information Commissioner via the contact details at www.oaic.gov.au.

How can you contact us?

The contact details for our Privacy Officer are:

General Counsel and Company Secretary
WholeLife Pharmacy Pty Ltd
U3 9 Gardner Close
Milton QLD 4064
Telephone: 07 3521 4300
Email: privacy@wholelife.com.au

Updates to this Privacy Policy

We may amend this Privacy Policy from time to time by publishing an updated version at wholelife.com.au