App Privacy Notice

Introduction and your consent

This document sets out our policy relating to THE protection of the privacy of personal information provided on or in connection with or otherwise used on the Alliance Pharmacy mobile device Application (Alliance Pharmacy App).

This policy document is intended to enable users of the Alliance Pharmacy App to understand the types of personal information we collect, and what we do with that information in performing our functions and in relation to our privacy obligation. We are committed to complying with the Privacy Act 1998 (Cth) (Act) and committed to supporting the Australian Privacy Principals (APP). In addition, we are bound and committed to the privacy of health records contained in Health Legislation in every state.

When you submit your Personal Information on or through the Alliance Pharmacy App, you are consenting to the collection, use and disclosure of your personal information as set forth in this Privacy Policy.

Who are you dealing with when you activate the Alliance Pharmacy App?

The Alliance Pharmacy App is a skinned version of the Alliance Pharmacy, which is a mobile

application provided by your selected pharmacy or selected pharmacies. myPharmacyLink was built and is operated by GuildLink Pty Limited (ABN 83 090 249 960), www.guildlink.com.au, (owned by the Pharmacy Guild of Australia) (GuildLink) using the GuildCare platform.

Alliance Pharmacy is owned and operated by Pharmacy Alliance ABN 92 103 792 (Pharmacy Alliance), a member-based organisation with over 650 independent pharmacy members across Australia. We provide procurement, marketing, IT, operational and HR support to our members.

Guildlink and Pharmacy Alliance are collectively referred to in this Privacy Notice as “we”, “us” and “our” (as the context requires).

Alliance Pharmacy is your local pharmacy, each is independently owned by people who have a passion for the health of the community they work in. Every Alliance Pharmacy is a little bit different, because every local pharmacy is focused on serving the unique needs of their own local community.

What does the Alliance Pharmacy App do?

The Alliance Pharmacy App enables you to:

  • see your prescription history that GuildLink and your selected pharmacy/ies hold about you;
  • see your professional services history (such as blood pressure results) that your selected pharmacy/ies and GuildLink holds about you;
  • receive information and updates on services relevant to your prescription and professional services history from either your selected pharmacy/ies or from GuildLink including advice, information, alerts, invitations and warnings;
  • receive marketing information relevant to your prescription and professional services history from either your selected pharmacy/ies or from GuildLink; and
  • manage your health by:
    • telling you about when your next professional service should be completed;
    • delivering to you any administrative notices, health alerts and communications relevant to your prescription and professional services history;
    • fulfilling your requests for certain products and services;
    • enabling you to add nominated healthcare-related service providers into the Alliance Pharmacy App as a quick reference functionality;
    • providing map/directions functionality to your nominated healthcare-related service providers;
    • providing you with a click to call your nominated health care service provider capability;
    • providing you with Consumer Medicines Information (CMI);
    • providing you with medicines images;
    • reminding you to take your medication;
    • telling you when you will need to refill your prescription;
    • telling you when your prescriptions will expire; and
    • giving you important information about your medication.

What personal information is shown on the Alliance Pharmacy App?

The Alliance Pharmacy App shows you information only about you that your Alliance Pharmacy selected pharmacy/ies hold/s about you. Prescription information or professional service information about you held by non-selected pharmacies will not appear in your Alliance Pharmacy App.

If you want to use the Alliance Pharmacy App to access information held about you by more than one pharmacy, each new pharmacy you select will ask you for relevant identification documents in order to enter into GuildLink’s GuildCare database. This ensures that the Alliance Pharmacy App matches you correctly to your prescription and professional services information related to each respective pharmacy.

If you want to use the Alliance Pharmacy App to manage medications on behalf of another person, such as your parent, spouse, sibling or child, you must give the pharmacist that person’s details and show the pharmacist that you either have that person’s consent or the authority to act on their behalf.

If a child, or another related person to you, who is aged 16 or under shares the same Medicare card as you (Minor), once you register with the Alliance Pharmacy App, it may allow you to also access that Minor’s information held on the GuildCare GuildCare database. If you do not have the consent of the Minor to access such information, or authority to act on their behalf, then you should not do so.

How is information about you collected for the Alliance Pharmacy App?

Pharmacies collect prescription and professional service information (such as results from blood pressure testing) from you when you give them a prescription to fill, or you ask them to provide a professional service to you. Pharmacies store this information in GuildLink’s GuildCare database and the Alliance Pharmacy App enables you to see this information.

GuildLink’s GuildCare database (which is used for the Alliance Pharmacy App) will also hold data about how you use the Alliance Pharmacy App, such as how often you use the Alliance Pharmacy App and which aspects of the Alliance Pharmacy App you make the most use of. This information includes the following.

  • We will also collect any personal information (including your medical, prescription and professional service information) that you enter into, or provide via, the Alliance Pharmacy App when you use the app. This information will also be stored on GuildLink’s GuildCare database and accessible on the Alliance Pharmacy App.
  • Before allowing you to use the Alliance Pharmacy App, either we (through our online identity verification process) or your selected pharmacy/ies (in person) will ask you to provide identity information to ensure Alliance Pharmacy can match you to your prescription and/or professional service history.
    • If you don’t provide this identity information, you won’t be able to use the Alliance Pharmacy App. If you sign up in person at a pharmacy, the selected pharmacy will not store the original copies of your identity documents but may keep a note of what identity document you showed to them.
    • If you sign up electronically, we do not keep any record of any identity documents you upload or provide via the online identity verification process.

However, that information is stored on the Guildlink GuildCare Database and is accessible on the Alliance Pharmacy App.

  • Via the Alliance Pharmacy App, GuildLink and your selected pharmacy/ies also collect:
  • your mobile phone number so that it can SMS you an activation code to set up your account;
  • your email address so that you can re-set your password for the Alliance Pharmacy App if you need to; and
  • your Medicare number to verify your identity and ensure your records match those held on the GuildLink database.

How do we use your personal information?

Alliance Pharmacy and GuildLink use your prescription and professional services information for the purpose of providing you with the services outlined above.

GuildLink also uses the information for market research, project planning, troubleshooting, detecting and protecting against error, fraud and other criminal activities, statistical analysis and reporting on trends in pharmacy-related service delivery, for analysis and reporting to government on health and health-related trends, to evaluate the effectiveness, efficacy and value of he Alliance Pharmacy App and for providing commercial services. GuildLink sells reports of aggregated de-identified information about these matters to third parties. The reports do not show information about specific Alliance Pharmacy App users and will not disclose any personal information about you held by your selected pharmacy/ies or which you enter into the Alliance Pharmacy App.

GuildLink and the selected pharmacy/ies may use the prescription and professional service information it holds about you to provide you with service-related communications. In addition, GuildLink and the selected pharmacy/ies may also provide you with marketing material which is unrelated to your prescription and professional services. You may opt-out of receiving these marketing materials at any time by following the opt-out prompts in the marketing material. You will still, however, continue to receive prescription and professional service communications, alerts and/or notifications (that are not marketing-related) that are relevant to you.

What we won't do with your personal information (including disclosures)?

We will NOT:

  • store or send any of your prescription information overseas;
  • disclose specific prescription or professional services information about you to third parties unless you give express consent;
  • collect information about you other than the prescription and professional service related information we already hold, or as described in this notice, unless it is directly related to the

Alliance Pharmacy App and you would reasonably expect it or we have your specific consent; or

  • collect information about your location through the Alliance Pharmacy App.

Pharmacy Alliance Privacy Policy

Insofar as Pharmacy Alliance receives Personal Information as a result of you registering and/or using the Alliance Pharmacy App, this Privacy Policy applies to our holding and use of that information.

Pharmacy Alliance will not receive any health information of yours or concerning you that is otherwise visible or accessible on the Alliance Pharmacy App. Pharmacy Alliance may receive some or all of the following information about you that you record on the Alliance Pharmacy App:

  • Your name
  • E-mail address
  • Telephone number
  • Postal or delivery address
  • Date of birth
  • Gender
  • your nominated Alliance Pharmacy

All references to your Personal Information in the Pharmacy Alliance Privacy Policy is to that information.

This information is required for the following reasons:

  • your registration on the Alliance Pharmacy App; and
  • your use of the Alliance Pharmacy App.
If you would prefer that we do not collect any Personal Information from you, please do not provide us with any such information. You have no obligation to provide any information requested by us. If you do not provide this Personal Information, you cannot register for the Alliance Pharmacy App and you cannot use the Alliance Pharmacy App.

Use and disclosure of Personal Information

We do not use or share Personal Information for any purpose other than the purpose disclosed. By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.

We use your Personal Information for the purpose for which the information is collected, we use it to

  • to provide you a better service in terms of the app operation;
  • to notify you of opportunities (whether product, service, recruitment or job opportunity);
  • to notify you of products or services that we think you might be interested in
  • marketing and promotional purposes
  • for research purposes
  • disclosure by law
  • to our third-party service providers, including service providers, agents or contractors located both inside and outside Australian borders for the purpose of market research.

If you provide your Personal Information to us on or through the Alliance Pharmacy App, the information you provided may be used by us to include you in customer rewards programs, create and deliver to you direct mail, e-mails, SMS, surveys, or attend customer research or discussion groups or other communications containing products, services and event information, tips, promotions or competitions. If you prefer not to receive such information including those of any rewards program see section 5 below.

We may also contact you to respond to product questions or concerns that you may express. These types of communications are necessary to serve you, respond to your concerns and to provide the high level of customer service that we offer our customers.

We may retain other companies and individuals to perform functions consistent with our Privacy Policy on our behalf. Examples include customer support, specialists, hosting companies, web developers, internet service providers, fulfilment companies, marketing, analysis and research data analysis firms, data centres, cloud-based storage providers, customer relationship management providers, email service providers, financial and credit card institutions, insurers and external business advisors (such as auditors and lawyers). Such third parties may be provided with access to Personal Information needed to perform their functions but may not use such information for any other purpose. In all circumstances where your personal information is disclosed, we will ensure that these third parties undertake to protect your privacy.

These third parties may be located in and outside Australia. If you subsequently decide that you do not wish to receive information from them you may let us know by contacting us.

If you elect to register for, activate or use the Alliance Pharmacy App, the rule or terms and conditions for those events may indicate your Personal Information will be shared with third parties. By choosing to participate and submitting your Personal Information in that manner, you consent to the disclosure of your Personal Information to such third parties.

Direct Marketing

Where we have your express or implied consent, or where we are otherwise permitted by law, we may use your Personal Information to send you information about the products or services we offer, as well as other information that may be of interest to you. We may send this information by mail, email, SMS or telephone, on or via social media or other online channels (including customising online content advertised or displayed on our website or social media channels).

If you do not wish to receive direct marketing communications from us you may opt-out at any time by:

  • using the unsubscribe facility that we include commercial electronic messages (email or SMS)
  • by contacting us by e-mail healthmatters@alliancepharmacy.com.au
  • by contacting us via post: Privacy Officer, Pharmacy Alliance, Level 4 111 Coventry St, South Bank VIC 3006
  • by calling us on 03 9860 3300
If you opt out of all communications in-store or contacting us on any of the above details, if you opt out of customer reward programs such as Healthy Rewards will not have the effect of removing you from that program unless you specifically opt to do so.

Protection of your Personal Information

We take all reasonable steps to ensure that Personal Information we collect through the Alliance Pharmacy App is protected from unauthorised access, loss, misuse, disclosure or alteration. The Alliance Pharmacy App has electronic security systems in place, including the use of firewalls.

Despite our reasonable steps, we are unable to ensure or warrant the security of any Personal Information transmitted to us through the Alliance Pharmacy App. Accordingly, all Personal Information disclosure by you to us through the Alliance Pharmacy App is at your own risk and we are not liable for any unauthorised access to the Personal Information.

Although the Alliance Pharmacy App may contain links to or from external websites, those websites are not subject to our privacy standards, policies and procedures. We recommend that you make

your own enquiries as to the Privacy Policies of these third parties. We are in no way responsible for the privacy practices of these third parties. This Privacy Policy applies only to the information we collect on our sites.

Accessing and correcting the information Alliance Pharmacy keeps about you

We take reasonable steps to ensure that any personal information collected or held by us is accurate and up-to-date at the time of collecting, however, it is your responsibility to ensure that the information you provide us is accurate and that you advise us of any changes to your details and that you have the authority to provide this Personal Information.

You may contact us at any time and ask for its correction if you feel that the Personal Information we have about you is inaccurate or incomplete. Alternatively, you can also visit our website and log in to manage your Personal Information at any time by logging in with your username and password. Access to personal information on the website can only be performed by employees with a secure password, with access only performed when required. Access to this information is recorded by log files to track unauthorised access and modifications.

If we determine that Personal Information is no longer needed for any purpose, we will take reasonable steps to destroy or permanently de-identify that Personal Information, unless we are required by law or a court or tribunal to retain information.

You may at any time request access to the information that Alliance Pharmacy has collected from you. Alliance Pharmacy prefers that this request be in writing. All enquiries should be made by contacting Alliance Pharmacy in one of the ways below:

Email: healthmatters@alliancepharmacy.com.au

Phone: 03 9860 3300

In Writing: Privacy Officer, Pharmacy Alliance, Level 4 111 Coventry St, South Bank VIC 3006

Alliance Pharmacy may require that you provide sufficient identification before allowing you to access the personal information held about you. If Alliance Pharmacy is required or authorised by law to do so, it may refuse to provide you with access to this information.

General

Alliance Pharmacy reserves the right to amend this Privacy Policy at any time and notify you by publishing an updated version of the Policy on our website and the Alliance Pharmacy App.

As we may make changes at any time without notifying you, we suggest you periodically consult this Privacy Policy. Please note that our rights to use your Personal Information will be based on the Privacy Policy in effect at the time the information is used. Your continued use of our products, services or websites following any such amendment will be confirmation of your acceptance of the amendments. We reserve the right to modify this Privacy Policy at any time, so please review frequently.

This Privacy Policy is in effect as at 18 September 2019.

More privacy information including access and complaints handling

More information about the Privacy law and the Australian Privacy Principles is available from the

Federal Privacy Commissioner website www.privacy.gov.au

For Pharmacy Alliance: You can contact us at healthmatters@alliancepharmacy.com.au or by phone to 03 9860 3300.

Pharmacy Alliance Level 4 111 Coventry St, South Bank VIC 3006

For Guildlink: If you have any queries or complaints with regard to our collection, use or management of your personal information, please contact us at:

Email: privacyofficer@guildlink.com.au

Address: PO Box A284, Sydney South NSW 1235

You can get more information about privacy and the Alliance Pharmacy App, including how to get access to and/or correct the information GuildLink, pharmacies and the Alliance Pharmacy hold about you and what to do if you have an inquiry or complaint in our privacy policy, at http://www.guildlink.com.au/guildlink/privacy-policy1/

You can get more information about how to get access to and/or correct the information Pharmacy Alliance holds about you and what to do if you have an inquiry or complaint in our privacy policy, at https://alliancepharmacy.com.au/privacy