This statement includes information about:
Date: March 2015
Your privacy is important to us.
KCI Medical Australia Pty Ltd (ABN 47 056 073 468) (KCI, we or us), a member of the Acelity Group of Companies, takes such steps as are reasonable in the circumstances to protect and maintain your privacy. KCI takes its obligations under the Privacy Act 1988 and the Australian Privacy Principles (APPs) seriously.
Personal Information and Sensitive Information
Personal information” is any information about an identified individual or an individual who is reasonably identifiable, regardless of whether the information is true or not.
“Sensitive information” includes, for example, the following:
- health information about an individual;
- genetic and biometric information about an individual; and
- information or an opinion about an individual’s racial or ethnic origin, membership of a professional association, trade association or trade union (which is also personal information).
What personal information and sensitive information do we collect?
The type of information we collect from you will depend upon the type of interaction you have with us.
Broadly speaking, the types of personal and/or sensitive information that we collect may include:
- from our customers and suppliers - full names of key contacts, employer name, work contact details (including address, phone number, fax number and email address);
- in respect of patients - patient name, date of birth, gender, address, phone number, wound details (including descriptions, measurements and photographs) and other health- related information, private health insurance details; and
- from job applicants and employees - full name, contact details (including address, phone number and email address), driver’s licence details, job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency).
We may collect personal and/or sensitive information from you in a variety of ways, including the following:
- when you request the supply and /or delivery of one of our medical products;
- when you request a quote for our products and/or services or wish to arrange private health insurer funding, for example, when an application for funding is submitted to us;
- during the clinical management process when using our products or services;
- arrange payment for use of our products and/or services;
- visit our Website and any other webpage that we own and manage;
- when you manage/change your customer and/or patient account information;
- contact us by phone, email, post or via the Website;
- when you register for and/or attend one of our Education Sessions;
- subscribe to receive our newsletter or promotional materials or sign up to a mailing list; and/or
- participate in surveys, such as our Customer Service Survey, or competitions or other promotional activities.
KCI may also collect your personal information from third parties. This may include (but is not limited to) the collection of your personal and/or sensitive information from:
- your treating doctor(s), hospital or clinic;
- nursing service providers who may provide services to you in your home;
- someone duly authorised to act on your behalf;
- your private health insurer;
- health records which may be provided to us by, for example, your hospital or treating doctor etc; the operator of our Customer Service Call Centre, when calls are made to the Centre outside 8.30am to 5pm (AEST) Monday to Friday; and
- recruiters we have retained and from referees you have provided in support of a job application.
From time to time, you may be able to visit our Website or deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain information that we require, we may not be able to provide you with the products and/or services that you seek.
How do we use your personal and/or sensitive information?
The personal and sensitive information we collect may be used in a number of ways including:
- service delivery and order fulfilment, for example, providing our products to hospitals for use with patients and arranging for the pick-up and delivery of our products to patients in their homes;
- liaising with treating doctors, specialists, hospitals and nursing service providers in respect of the delivery of our products and services to patients and their ongoing treatment using our products and services;
- liaising with private health insurers in respect of the funding arrangements for patients’ use of our products and services;
- facilitating and managing the treatment of individuals using our medical therapy products in their home;
- generating bills, managing accounts and carrying out debt-recovery functions;
- providing customer and/or technical support and other customer relationship management functions (for example enabling the fitting, activation, maintenance and management of a patient’s use of our products;
- dealing with enquiries or complaints;
- collecting and analysing product performance, service and reliability data;
- if you are a health care professional, providing KCI Medical Education Sessions and other training in respect of the use of our medical therapy products which may include marketing these products to you. You may be contacted by post or, when you have given us permission to do so, by telephone, email, text messaging or other established electronic methods;
- carrying out market research and product analysis and development;
- complying with our obligations under the law;
- training our staff;
- in the event of a change of business ownership, merger, sale or other business transaction, transferring your information to a successor entity;
- for various communications and marketing purposes and product and therapy enhancement;
- conducting our internal business and management processes, for example accounting or auditing purposes; and
- for any other purposes that would be reasonably expected.
KCI recognises the need to adequately protect the privacy of all its patients, especially the privacy of children. In circumstances where KCI interacts with younger users of our products, KCI will obtain appropriate parental consent according to applicable privacy and data protection laws to ensure that parents and guardians are kept well informed and involved in all such interactions.
How to opt-out of marketing materials?
From time to time, if you are a healthcare professional, we may use your personal information for the purposes of marketing our medical therapy products and services or to inform you of new products, promotions or events, including training sessions that we believe you may be interested in. If you no longer wish to receive our marketing communications, you can opt out by:
- writing to us at the Contact Details below and informing us that you no longer wish to receive these marketing materials;
- in relation to any direct marketing email, clicking the “unsubscribe” link at the bottom of each email; or
- informing your usual KCI Representative.
Please be aware that we may still need to send you essential information (rather than marketing information) from time to time.
Is personal and/or sensitive information disclosed to third parties?
KCI may disclose personal and/or sensitive information to third parties in certain circumstances including (but not limited to) the following:
- in respect of the availability, use and delivery of our products and services - to treating doctors, specialists, hospital staff, third party nursing service providers and private health insurers;
- to other members of the Acelity Group of Companies (including those who may be located overseas);
- to other third parties who we engage to help us run our business - such as couriers and other delivery service providers to arrange the delivery / collection of our products; pay roll service providers; debt collection agencies and other parties that assist with debt-recovery functions;
- your duly authorised representatives (such as your guardian, care-giver, healthcare professional, hospital, health insurer or other health service provider);
- to our professional advisors, including lawyers, accountants, tax advisors and auditors; or
- law enforcement bodies, Courts of law or as otherwise required or authorised by law;
- regulatory or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies;
- any other person or for any other purposes that would be reasonably expected.
With your consent, we may also transfer personal and sensitive information (including, but not limited to, audio-visual materials such as video, audio or photographs) to overseas recipients for communications and marketing purposes, product and therapy enhancement or for any of the purposes listed above. Wound details, including photos, may be incorporated into marketing or clinical materials, which may be distributed to recipients anywhere in the world.
Does the Website use “Cookies”?
Cookies are small text files that may be placed on your computer or other device by websites when you visit them. Cookies enable KCI to recognise your device on a subsequent visit by that device to our Website and allows us to deliver a more personalised experience by providing information to us. Cookies are essential for some website functions and these functions will not work in the absence of those cookies.
You can use the browser privacy functions to clear the cookies already on your computer or to block cookies in the future by altering the browser privacy settings. However, please note this may cause some of the functionality of the Website to not work correctly.
Third Party Websites
How accurate is the personal information we hold about you?
We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of the information we hold depends to a large extent on the information you provide. To ensure that we have your most current personal information, please contact us when your information changes (e.g. if a customer or patient, complete and submit a KCI Change of Circumstances Form or KCI Cease Rental Advice Form).
What security measures do we use to protect your personal information?
The security of your personal information is given a high priority. We take such steps as are reasonable to securely store your personal information so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:
- storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
- using industry-standard encryption technologies when transferring or receiving sensitive information;
- restrictions are placed on the electronic transfer of files; and
- our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.
KCI takes such steps as reasonable, in the circumstances, to destroy personal and sensitive information when the information is no longer required for any purpose for which it may be used or disclosed by KCI and KCI is no longer required by law to retain the information.
Can you access the personal and/or sensitive information we hold about you?
Yes, however there are some exceptions by law, which we will explain to you if relevant to your request. To request access to your information, send an email to firstname.lastname@example.org. To protect your privacy, we will take reasonable steps to verify your identity before providing you with access to your information. We may charge reasonable costs for responding to your request and will respond to your request within a reasonable time.
If we refuse to grant you access, we will provide you with a written notice setting out the reasons for our refusal and the mechanisms you may use to complain about our decision.
Can you seek correction of the personal information we hold about you?
If you think your personal information may be inaccurate, incomplete or out of date, you can request it to be updated or corrected by sending an email to email@example.com. We will respond to your request within 30 days and we will not charge a fee for responding to your request. KCI may need to flag your records with a suitable explanation rather than changing or deleting the information. To protect your privacy, we will take reasonable steps to verify your identity before correcting or adding notes to our records. If we refuse to correct your information, we will provide you with a written notice setting out the reasons for our refusal and the mechanisms you may use to complain about our decision.
How can you report a breach of your privacy?
If you have any concerns or complaints about a breach of your privacy or the way we have handled your personal information, please contact us by sending an email to firstname.lastname@example.org.
We will then investigate your complaint and endeavour to provide you with our response within a reasonable time after receiving your complaint. If, after receiving our response, you still consider your privacy complaint remains unresolved, you may then, for example, refer your concern to the Australian Privacy Commissioner.
For any other questions regarding privacy, please send an email to email@example.com or call on 1300 524 822.
Appendix: List of Countries