1.1

This Privacy Policy explains how Daiichi Sankyo Australia Pty Ltd (ACN 654 901 989) (Daiichi Sankyo) manage the personal (including sensitive) information (Information) that we collect, hold, use and disclose and how to contact us if you have any further queries about our management of your Information.

1.2

This Privacy Policy applies to you only to the extent that the collection and handling of your Information is subject to the Privacy Act 1988 (Cth) (Privacy Act).

2.1

Where the collection or handling of your personal information by us is subject to the Privacy Act, we must comply with the requirements of that Act. The Privacy Act regulates the manner in which personal information is handled throughout its lifecycle, from collection to use and disclosure, storage, accessibility and disposal.

2.2

Personal information is 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.

2.3

Special provisions apply to the collection of personal information which is sensitive information. This includes health information and information about a person's race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences, criminal history, biometric information that is to be used for the purpose of automated biometric verification and biometric identification and biometric templates.

3.1

If you are a healthcare practitioner, the types of Information that we may collect includes:

• (a) identifying and contact information such as your name, work title, clinical field, work address, phone number and email address;
• (b) work related information such as biographies, work histories and conference attendances;
• (c) travel information such as passport details;
• (d) information about any payments or non-monetary benefits provided to you by Daiichi Sankyo (including if you provide services to Daiichi Sankyo, Daiichi Sankyo sponsors you to attend a conference or you are invited by Daiichi Sankyo to attend a medical education event);
• (e) information about your prescribing habits and your views on medical and/or patient related issues; and
• (f) information about the research projects and clinical trials you may be involved in.

3.2

If you are not a healthcare practitioner or a patient, but otherwise have a relationship, or interact, with Daiichi Sankyo (such as a patient advocate or government administrator), the types of Information that we may collect include identifying and contact information such as your name, work address, phone number and email address and other Information that may be relevant to your relationship or interaction with Daiichi Sankyo.

3.3

Daiichi Sankyo does not actively seek to collect the Information of patients. We may collect the Information of patients in response to queries we receive from patients and to fulfil any requests made by patients. The types of Information we may collect from patients in these circumstances include:

• (a) identifying and contact information such as your name, address, phone number and email address; and
• (b) information about your health condition including any medications you are taking and any adverse events.

We may also collect de-identified patient information as part of administering early access, compassionate use and patient support programs.

3.4

If you are an employee, contractor or job applicant, we may collect Information including name, address, phone number, email address, financial and banking information, information about the personnel's skills, qualifications, experience and references, and results of background checks.

3.5

To the extent required by the Privacy Act:

• (a) Daiichi Sankyo will not collect Information about you unless that Information is reasonably necessary for one or more of our functions or activities; and
• (b) Daiichi Sankyo will collect Information only by lawful and fair means.

4 

4.1

We typically collect your Information directly from you where it is reasonable and practicable to do so. Generally, we may collect your Information in a number ways including:

• (a) if you are a healthcare practitioner, during visits to you;
• (b) during telephone calls with you;
• (c) from written or electronic correspondence you may have with us; and
• (d) through forms you complete and submit to us (such as adverse event reporting forms).

4.2

We may also collect Information about you from third parties such as from:

• (a) electronic directories of healthcare providers which we subscribe to or are available online;
• (b) organisations that we engage or have arrangements with to assist us to carry out our functions and activities (such as our alliance partners and market research organisations); and
• (c) healthcare providers or your colleagues.

We may also collect your Information from public sources.

5.1

Depending on the nature of your relationship with Daiichi Sankyo, Daiichi Sankyo may collect, hold, use and disclose your Information for any of the following purposes:

• (a) to manage our relationship with you;
• (b) general sales and marketing, including to contact you to provide you with information about, and to discuss, Daiichi Sankyo products and other matters;
• (c) to assist in the organisation of educational events and other meetings (including inviting speakers and attendees) and sponsorship for attendance at educational events and other meetings (including to organise travel to such events/meetings and accommodation);
• (d) to identify investigators for, establish and conduct clinical trials (including clinical trials run by a related body corporate of Daiichi Sankyo), to establish and run medical advisory boards, and to acquire general opinions on medical and/or patient related issues;
• (e) to conduct market research, including in relation to prescribing practices;
• (f) to assist in providing you with medical information relevant to Daiichi Sankyo products;
• (g) to send educational materials to you and/or other information;
• (h) to administer early access, compassionate use and patient support programs;
• (i) to evaluate and continue to develop and improve our products, services and business processes;
• (j) to comply with Daiichi Sankyo's legislative obligations, regulatory obligations and any requirements under the Medicines Australia Code of Conduct (MA Code), including in relation to reporting of payments or non-monetary benefits to healthcare practitioners;
• (k) to comply with the internal policies and procedures of Daiichi Sankyo and its related bodies corporate including in relation to reporting of payments or non-monetary benefits provided to healthcare practitioners;
• (l) adverse event reporting;
• (m) if you are a patient, to respond to your query, including to contact you for follow up purposes and maintain a record of queries raised and responses provided;
• (n) for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.

Our functions and activities may change from time to time.

5.2

If you provide your email address, telephone and/or mobile phone number to Daiichi Sankyo, you also consent to Daiichi Sankyo using your email address, telephone and/or mobile phone number to contact you (including by telephone call, SMS or email) for any of the above purposes. Your consent will remain current until you advise us otherwise by contacting the Privacy Officer using the contact details below.

6.1

Daiichi Sankyo may engage or have arrangements with other persons or organisations (for example, our alliance partners within whom we have a collaboration or joint venture for all or part of our business, professional conference organisers, market research organisations and other service providers) to assist Daiichi Sankyo in carrying out the above purposes. Your Information may be disclosed to such persons or organisations for these purposes and, in providing a service, they may contact you directly. In some circumstances they may disclose Information they collected from you to Daiichi Sankyo for one or more of the purposes already mentioned. Daiichi Sankyo will hold, use and disclose all Information it collects from third parties about you in the manner described in this Privacy Policy.

6.2

Daiichi Sankyo may also disclose your Information to:

• (a) its related bodies corporate (including outside Australia);
• (b) regulatory authorities when notifying adverse events (including outside Australia); and
• (c) parties involved in a prospective or actual transfer of Daiichi Sankyo's assets or business.

7.1

If you are a healthcare practitioner and you receive any payment or non-monetary benefit from Daiichi Sankyo (including if you provide medical advisory services to Daiichi Sankyo, Daiichi Sankyo sponsors you to attend a conference or you are invited by Daiichi Sankyo to attend a medical education event), Daiichi Sankyo will collect Information about you including the following:

• (a) name and profession;
• (b) business/practice address;
• (c) a description of any services and benefits you receive from Daiichi Sankyo and details of any services, activities and events in respect of which you were engaged by Daiichi Sankyo including relevant dates;
• (d) the amount of the financial payment or the value of any non-monetary benefits you individually received from Daiichi Sankyo including air travel, accommodation costs (room rate) and registration fees paid by Daiichi Sankyo and/or reimbursed to you; and
• (e) any financial payments made or non-monetary benefits given to third parties as directed by you,

(Transparency Data).

7.2

Daiichi Sankyo will disclose the Transparency Data to its related bodies corporate (including outside Australia).

7.3

In accordance with the MA Code, or other applicable international regulations, Daiichi Sankyo and/or its related bodies corporate will also publicly disclose some or all of the Transparency Data. Specifically, in accordance with the transparency obligations in the MA Code, Daiichi Sankyo will report Transparency Data to Medicines Australia which will then be published in a manner which individually identifies you on https://disclosureaustralia.com.au/. Daiichi Sankyo will give you an opportunity to review and submit corrections to the Transparency Data before that information is published.

7.4

If you are a healthcare practitioner, you are responsible for obtaining any necessary approvals (e.g., from your employer or professional body) for Daiichi Sankyo and its related bodies corporate to collect, use and disclose the Transparency Data as described above.

7.5

By accepting payment or a non-monetary benefit from Daiichi Sankyo, you acknowledge the collection, use and disclosure of the Transparency Data by Daiichi Sankyo and its related bodies corporate as described above. If you do not want the financial payment or non-monetary benefit provided to you by Daiichi Sankyo publicly disclosed, you should not engage in the relevant services/activities/events or accept any services and benefits from Daiichi Sankyo.

9.1

We generally store your Information electronically on servers located in Japan with access only available by password.

9.2

We aim to store your Information securely and have a range of security controls in place (including physical, technical and procedural safeguards) designed to protect your Information.

9.3

To the extent required by the Privacy Act, Daiichi Sankyo will take reasonable steps to:

• (a) make sure that the Information that we collect, hold, use and disclose is accurate, complete and up to date; and
• (b) protect the Information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.

9.4

We retain Information that we hold for as long as it is necessary to perform the function in relation to which the Information was collected. We may also retain Information for longer periods to comply with legislative requirements for document retention.

10.1

As mentioned above, Daiichi Sankyo will store your Information on servers in Japan. Further, some organisations to which we disclose your Information may be located, or may store your Information on computer servers, overseas. For example, Daiichi Sankyo:

• (a) may share your Information (including Transparency Data as described above) with personnel of Daiichi Sankyo's related bodies corporate in the United States of America, Europe, Asia and Brazil (a list of countries in which Daiichi Sankyo has related bodies corporate can be found at Global Presence - Corporate Information - About Us - Daiichi Sankyo); and
• (b) may disclose your Information to overseas regulatory authorities, overseas event/conference organisers, international clinical trial sites and, where Daiichi Sankyo may be organising travel on your behalf, overseas travel agents.

If Daiichi Sankyo transfers your Information to another party outside Australia, we will take such steps as are reasonable in the circumstances to ensure that the overseas recipient will not breach the privacy principles set out in the Privacy Act in relation to the Information.

11.1

If you are a healthcare practitioner, and if you provide your consent for us to do so, we may use your Information to contact you (including by telephone call, SMS, email or mail) about Daiichi Sankyo products and services that we think may be of interest to you. This may involve Daiichi Sankyo providing your name and contact details to our marketing service providers, which they will then use for marketing Daiichi Sankyo products and services to you.

11.2

If you do not want to receive marketing communications from Daiichi Sankyo, you can withdraw your consent at any time by contacting the Privacy Officer in writing using the contact details below or by unsubscribing using the unsubscribe link in any email or SMS which you receive from us.

11.3

If you do not wish to receive marketing material from Daiichi Sankyo, please note that Daiichi Sankyo may still contact you to provide you with other types of non-marketing information such as changes to PBS listings.

11.4

Daiichi Sankyo does not use Information of patients or non-healthcare practitioner consumers for marketing purposes.

12.1

Please contact Daiichi Sakyo if you would like to seek access to or request that we correct the Information we hold about you:

• (a) By mail: Level 2, Building D, 12-24 Talavera Road, Macquarie Park, NSW 2113
• (b) By telephone: +61 2 8527 9909
• (c) By email: dsau_privacy@daiichisankyo.com

12.2

Daiichi Sankyo will generally provide you with access to your Information if practicable, and will take reasonable steps to amend any Information about you which is inaccurate or out of date. In some circumstances and in accordance with the Privacy Act, we may not permit you access to your Information, or may refuse to correct your Information, in which case we will provide you reasons for this decision.

13.1

If you have any concerns or complaints about the manner in which Daiichi Sankyo have collected or handled your Information, please advise us of your concern or complaint in writing and send it to us using the email address or mailing address set out above. Your concern or complaint will be considered or investigated and we will endeavour to respond to your complaint within 30 days.

13.2

It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the Office of Australian Information Commissioner who may investigate your complaint further.