George Medicines Pty Limited, together with its subsidiaries, affiliates, and related entities (“George Medicines UK Ltd,” “us,” “we,” “our”), is committed to protecting the privacy and security of the personal data we collect about end customers and users of our services (“you/your”). This privacy notice explains what personal data we collect about you and how we use it.
George Medicines Pty Limited operates primarily out of Australia and maintains an entity in the United Kingdom. Personal information collected by George Medicines UK Ltd may be accessed, processed, or stored in Australia, the United Kingdom, or other locations where we or our service providers maintain facilities. Regardless of location, we are committed to protecting your personal information in accordance with this Privacy Policy and applicable privacy laws.
Please read this privacy notice carefully, as it provides important information about how we handle your personal information and your rights. If you have any questions about any aspect of this privacy notice, you can contact us using the information provided below or by emailing us at privacy@george-medicines.com.
This privacy notice is provided to you to ensure transparency concerning the collection, use and disclosure of your Personal Data by George Medicines for purposes related to the conduct of clinical trials and non-interventional studies (collectively “Clinical Studies”) sponsored or organised by us, and/or our affiliates which are being carried at your Clinical Trial Site (the “Site”). For the purposes described in this Privacy Notice, George Medicines Pty Limited is responsible for processing your Personal Data by acting as a “Controller”.
This notice applies to is addressed to:
- Volunteers for clinical trials (“Trial Volunteers”)
- Doctors and staff at the medical facilities we work with (“Medical Staff”)
- Individuals who use the Contact George Medicines form on our website (“Website Contacts”)
- Employees of our suppliers (“Suppliers”)
- Clinical investigators (principal investigators, sub-investigators or co-investigators)
- Other site staff, such as nurses, pharmacists or technicians, whose Personal Data may be processed in the course of the clinical trials and studies sponsored or organised by George Medicines.
What types of personal information do we collect and why?
We collect personal information reasonably necessary for one or more functions or activities as a medical research organisation. The types of personal information we collect may include:
- name, identification number, address and other contact details,
- financial information (e.g. bank account number),
- qualifications, publications and information contained in the CV you provide to us where necessary,
- previous experience and other information regarding your participation in Clinical Studies within or outside of George Medicines and the training you have received,
- technical data related to your use of George Medicines website or IT systems.
We may collect additional personal information Depending on the purpose of our interaction with you. More details about the personal information we collect (and why) are provided below.
Human Research Studies / Trials
We (or an approved third party operating on our behalf) will collect personal information and health information (and, at times, other sensitive information) from individuals who participate in human research studies and clinical trials undertaken by George Medicines:
Such information collected may include:
- gender, nationality, heritage, and date of birth;
- medical history and treatments;
- Medicare number (or similar) and private health insurance information;
- current medications and treatments;
- health services and treatments;
- symptoms, test results and hospital care; and
- consequential health factors.
The information is collected for medical research and analysis pertaining to the research study or trial, to comply with laws and regulatory guidelines relating to medical research and clinical trials, and to substantiate the findings and publication of research results.
We may also collect the personal information of health practitioners and health providers who are involved in the care of study participants (e.g. general practitioners, physiotherapists, and other healthcare service providers). Such information collected may include name, address, contact details, professional qualifications, experience, and interaction records with us (as part of the research study or trial). This information is collected for administration, management, operation of George Medicines, as well as for the research study or trial.
We will also collect the personal information of medical experts, researchers, and other professionals advising on, overseeing, or assisting in the conduct of a particular research study or trial. The information collected will include name, address, contact details, professional qualifications and experience, and registration information.
We may collate statistical data from study/trial results that we have collected over years for the purposes of future research or advising on healthcare policy to Governments and decisionmakers.
General Activities
As part of business operations, we will capture and record personal information from our dealings with partners, business alliances and service providers. Such information is collected for administrative, management, and audit purposes.
We may collect personal information (e.g., name and contact details) from those who contact us (by phone or in person) and those who access our websites (refer to the ‘How do we collect and hold your personal information’ section below). Such information is collected to deal with you and improve our services.
We are required to collect personal information from donors and supporters of TGI to comply with laws and issue tax receipts. Information collected will include name, contact details and payment details. We may collect personal information when we are canvassing recruitment of staff and PhD students. You may also supply personal information to us when applying for open positions, and we may collect your personal information from third parties (e.g. referees) as part of the assessment and recruitment process. Information collected will include educational and academic background, work history, skill set and capabilities. We will collect similar personal information from volunteers who apply to work with George Medicines.
Processing Purpose and Legal Basis
Who has access to Personal Data?
Personal data may be accessed by or transferred to:
- our personnel (including those in our Clinical Trial, Patient Safety, Medical Information, Quality Assurance, and Legal departments) and other companies included in the Clinical Trial;
- our partners, e.g. other pharmaceutical and medical device companies.
- suppliers and services providers acting on behalf of George Medicines that provide services and products to us. These third parties are contractually obliged to protect the confidentiality and security of your Personal Data in compliance with applicable laws.
Personal data may also be shared with national and/or international regulatory authorities, other enforcement agencies, commissions, courts or ethics committees, including, if applicable, those based in different jurisdictions, to comply with local laws, regulations, or pharmaceutical industry codes applicable to George Medicines. Therefore, we may disclose information such as the Site’s and/or investigator’s name, Site contact information, name of the Clinical Study, copy of the clinical trial agreement, and costs and fees relating to the Site’s activities.
Research Studies
We may disclose your personal information to our staff, related parties, and approved third parties (e.g. agents, service providers, collaborators and research partners) who are working on the study or research program for which your personal information was collected; but only to such persons who need to know. Our staff must comply with privacy and confidentiality terms as part of their employment with us. To be an approved third-party, that party must be subject to similar privacy and confidentiality laws or have a professional and/or contractual obligation of confidence.
We may also disclose your personal information as directed or permitted by law or court order. Depending on the circumstances and the location where the study or research program is being conducted or coordinated, the above-mentioned may involve a cross-border disclosure. Our studies are often internationally based and our staff, agents, service providers, collaborators and research partners may be located overseas, e.g. Canada, the United Kingdom, the European Union, India and China. This will be explained in the study protocol and information documents.
Whenever possible, your personal information will be de-identified (and aggregated with others) before disclosure.
How do we collect and hold your personal information?
Research Studies
We aim to collect your personal information directly from you:
- when you first contact us (e.g., by phone, in person, email or via our website);
- when you agree to participate in a research study or trial (e.g. through the study information/consent process); and
- when dealing with us as part of ordinary business.
We may collect your personal information from a third party, such as your medical or health provider (e.g., GP, hospital), and that provider will give you an information document (including requisite privacy disclosures).
Our websites
When accessing our websites, we may make a record of your user service address and internet provider name and address, the date and time of your visit, the pages you accessed and any documents downloaded, any website visited before accessing our site and the type of browser used. This information (which is unlikely to contain personal information) is collected to monitor the activity on our websites (including the popularity of certain pages and information presented on our websites, and linkages to information), to consider improvements to the delivery, presentation and types of information our websites (including cost/benefit analysis), and ensure the protection of our intellectual property and reputation.
Our websites use cookies, which are small text files stored in your local browser cache when you visit a website. Using cookies makes it possible to recognise the visitor’s browser to optimise the website and simplify its use. We do not use information collected via cookies to determine visitor’s identity. Most browsers are set up to accept these cookies automatically. Refer to our Cookie Policy for more information.
Where is personal information stored?
Personal data may be processed, accessed, or stored in a country outside the country where you are located, which may not offer the same level of protection of personal data. If we transfer your Personal Data to other jurisdictions, we will make sure to protect your Personal Data by (i) applying the level of protection required under the local data protection/privacy laws applicable in the country of destination, (ii) acting in accordance with our policies and standards and, (iii) for entities located in the European Economic Area (i.e. the EU Member States plus Iceland, Liechtenstein and Norway, the “EEA”), unless otherwise specified or required, by transferring your Personal Data on the basis of standard contractual clauses approved by the European Commission. You may request additional information in relation to international transfers of Personal Data and obtain a copy of the adequate safeguard put in place by exercising your rights as described below.
For intra-group transfers of Personal Data, we have adopted Binding Corporate Rules, a system of principles, rules and tools, provided by European law, to ensure effective levels of data protection relating to transfers of Personal Data outside the EEA and Switzerland.
Holding personal information
We hold personal information in paper-based and electronic records and systems. Personal information collected in paper-based documents may be converted to electronic form for storage (with the original paper-based documents either archived or securely destroyed).
George Medicines uses physical security and other measures to ensure that personal information is protected from misuse, interference and loss, and from unauthorised access, modification and disclosure.
How long do we store Personal Data?
We will keep your Personal Data as long as needed to provide you with our services, and for legal and regulatory requirements. We will retain your personal data for a reasonable period after that to:
- enable us to meet our contractual obligations;
- enable us to comply with legal and regulatory requirements; and
- to deal with complaints and claims.
At the end of the applicable retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning. Please note that in certain countries we may be required to retain Clinical Study Documentation for a minimum of 25 years.
For individuals located in the EEA or UK
Your rights
If you are in the European Economic Area (collectively the EEA) or United Kingdom (UK), you will have certain rights under the GDPR or UK GDPR (as appliable):
These rights are not absolute and may not apply in all circumstances.
How can you access and seek correct of your personal information held by us, or exercise other rights under GDPR or UK GDPR?
You may request access to, or seek correction of, your personal information that is held by George Medicines or exercise other rights available to you under GDPR or UK GDPR (as applicable).
You can contact our representatives regarding matters pertaining to the GDPR or UK GDPR, by emailing privacy@george-medicines.com. Alternatively writing to:
We will generally not charge a fee for such requests, but we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Typically, we will respond to your request within 10 – 20 business days, but sometimes we may require more time depending on the circumstances.
In your request, please ensure that you provide a reply address so that we can contact you if we are unable to locate your personal information, if we need to verify your identity, or if we cannot carry out your request (in which case, we generally tell you why).
What should you do if you have a complaint about the handling of your personal information?
Please set out your complaint in writing to the Data Protection Officer as above.
Please provide sufficient information, so that the Data Protection Officer can consider your concerns and contact you. Typically, we will respond to your complaint within 10 – 20 business days.
If you are not satisfied with our response, or you consider that we may have breached our legal obligations, you are entitled to make a complaint as follows:
If you are in Australia, The Office of the Australia Privacy Commissioner can be contacted by telephone on 1300 363 992 or full contact details can be found online at www.oaic.gov.au.
If you are in the EEA, you may wish to lodge a complaint with a supervisory authority within the EEA. Please click here for a list of the national data protection authorities in the EEA.
If you are in the United Kingdom, you may wish to lodge a complaint with the Information Commissioner’s Office (ICO) via https://ico.org.uk/make-a-complaint/.
How are changes to this privacy policy made?
We may amend this Privacy Policy occasionally, with or without notice to you.
Please refer to our corporate website http://www.george-medicines.com/ for the latest copy.